Spill Prevention, Control, and Countermeasure Plans (SPCC’s) are required by the EPA when certain threshold amounts of stored oils are reached. See: 40 CFR, Subchapter D, Part 112.7. We find that there are often flaws or omissions in SPCC plans. They include:
- Failing to include oils stored in stationary equipment such as hydraulic systems and/or crankcases.
- The SPCC Plan did not have a signature of approval by management (40 CFR 112.7)
- The SPCC Plan was not certified by a PE (40 CFR 112.3(d))
- No spill history was included in the FRP (40 CFR 112.20(f)(2(i)(F))
- No self-determination criteria form was included in the SPCC Plan (40 CFR 112.20)
- The Plan lacks written procedures for inspections and for maintaining inspection records for 3 years (40 CFR 112.7(e))
- Personnel are not properly instructed in spill prevention procedures (40 CFR 112.7(f))
- Spill prevention briefings are not conducted for operating personnel (40 CFR 112.7(f)(3))
- Inspections are not conducted as required (40 CFR 112.7(e))
- Facility security measures, including fencing, gates, and/or security guards, are not mentioned in the SPCC Plan (40 CFR 112.7(g)(1))
These are but a few common gaps. We’ll discuss SPCC’s in more detail in an upcoming post.